Following feedback from the Michigan State Medical Society (MSMS), several specialty societies, individual physicians, and others, Blue Cross Blue Shield of Michigan (BCBSM) has clarified their recently announced Modifier 25 policy. Unfortunately, the clarification does not remove the across-the-board 50 percent reduction to office and outpatient E/M codes *99202‑*99205 (new patient) and *99212‑*99215 (established patient) when billed with modifier 25 on the same day as an eligible minor procedure. Therefore, MSMS continues to actively respond to and seek rescindment of this reimbursement policy change.
On February 6, 2026, MSMS sent a letter expressing concern and requesting a meeting. A second letter was sent to BCBSM on February 19th from MSMS and twenty-six co-signatories urging the policy be rescinded before the implementation date, sharing data supporting that request, and expressing concern about the potential impact on patient access and practice sustainability. While the requested meeting has not yet been scheduled, BCBSM has confirmed that it is in process. MSMS is also coordinating closely with specialty societies, physician organizations, and large medical groups to present unified feedback and specialty-specific data.
The recently released BCBSM Clarification to policy update on E/M codes appended with modifier 25 and FAQ document will be published in the April 2026 issue of The Record and is currently available via the Availity portal.
Clarifications to the Policy
- 90-day global surgical period removed:
Claims involving procedures with a 90-day global surgical period were included in error and have been removed from the policy.- E/M services related to a 90-day global procedure should be billed with modifier 57.
- There are no changes to payment for claims billed with modifier 57 under this modifier 25 policy.
- Revised exceptions:
Policy exceptions have been clarified and updated by the plan. - Minor Procedure defined:
- Defined by its global surgery package period, either 0 or 10 days
- Includes the procedure, any routine pre- and post-operative care as well as Evaluation and Management
- Often performed in the office or outpatient setting
- Generally low-risk and minimally invasive
Effective for claims with dates of service on or after May 1, 2026:
- Applicable office/outpatient E/M codes (99202–99205 and 99212–99215) that represent distinct and separately identifiable services, when billed with modifier 25 on the same calendar date as a minor procedure (0- or 10-day global period) by the same provider for the same patient, will be reimbursed at 50% of the contracted rate.
- The minor procedure will continue to be reimbursed at the full contracted rate.
- Preventive and administrative E/M services, as well as emergency department E/M codes (99281–99285), remain excluded from the reduction.
- Claims involving a 90-day global surgical period are excluded from this policy change.
This policy applies to patients enrolled in:
- Blue Cross Blue Shield of Michigan
- Blue Care Network
- Medicare Plus Blue (participating providers only)
- BCN Advantage (participating providers only)
- Blue Cross and Blue Shield Federal Employee Program
While the removal of the 90-day global period from the policy represents a clarification, the reduction in reimbursement for modifier 25 services associated with minor procedures remains a significant concern for many specialties. Practices that routinely provide medically necessary, separately identifiable E/M services on the same day as office-based procedures may still experience meaningful revenue reductions beginning in 2026.
MSMS will continue aggressive advocacy efforts and provide updates as discussions with BCBSM progress. If you wish to contact BCBSM directly regarding this policy change, email James D. Grant, MD, MBA, Senior Vice President and Chief Medical Officer, BCBSM, at Jgrant@bcbsm.com. Physicians who are willing to share specialty-specific examples or projected financial impacts are encouraged to contact Dara J. Barrera, MSMS Director of Health Quality, Equity and Technology, at djbarrera@msms.org.